Memorandum by the Royal National Institute
for the Blind (RNIB)
1. INTRODUCTION
The Royal National Institute for the Blind is
the largest organisation in the United Kingdom working with and
on behalf of blind and partially sighted people. We work to influence
the development of public policy at local, national and European
levels in the interests of visually impaired people. RNIB is a
leading member of the European Blind Union, which is the only
pan-European organisation representing the interests of blind
and partially sighted people, who number 1.7 million people in
the United Kingdom and 7.4 million people in the EU. As the profile
of the visually impaired population is biased towards the older
age groups, the increase in the number of elderly people across
the EU will be accompanied by an increase in the number of visually
impaired people.
2. GENERAL COMMENTS
RNIB believes that it is important for the EU
institutions and national governments/agencies to use the opportunity
presented by the coming e-commerce directive and the e-Europe
initiative to take steps to enable the United Kingdom's and EU's
visually impaired citizens to enjoy equal access to e-commerce.
If these opportunities are not used imaginatively to this end,
many people will face exclusion from this growing sector's services,
as well as providers of many online e-commerce services needlessly
excluding themselves from millions of potential customers.
3. SPECIFIC COMMENTS
(a) On question 2 posed by the Sub-Committee—RNIB
believes that the European Commission's eEurope Action Plan does
offer some realistic means of promoting e-commerce. We welcome
the early results of the eEurope consultation process, in which
RNIB took part, as posted on the Commission's "Feedback to
the eEurope mailbox page". In particular the Commission draws
attention to the suggestion that the Web Accessibility Initiative
(WAI) guidelines should be widely adopted, with the Commission
undertaking to actively consider this and encourage the Member
States to do likewise. We urge the Sub-Committee to add its support
to this suggestion in its reports to and contacts with the United
Kingdom's Government/EU institutions. Clearly an active promotion
of the WAI guidelines by the EU and Member States to the e-commerce
sector would assist e-commerce providers to meet the ambitions
of the e-commerce directive on subjects such as the duty to provide
information about themselves, as well as helping providers ensure
that avoidable design errors did not exclude them from millions
of potential customers.
(b) One potentially useful way to encourage best
practice amongst electronic commerce providers as regards accessibility
of their services to visually impaired and other disabled people,
would be for the Member States and Commission to consider means
of public recognition/financial incentives for service providers
who meet the standards of codes of conduct/standards agreements.
(c) The same Commission mailbox page also
records the support of industrial respondents for "sunset
clauses" to allow for regular updating of e-commerce regulations.
RNIB believes that such clauses should allow for updating of any
codes of conduct/standards agreements which we urge the EU institutions,
member states, e-commerce providers and consumer organisations
to agree. Crucially, disabled people's organisations such as the
European Blind Union and European Disability Forum need to be
involved in any such codes/standards preparation. As access technologies
and design for all/accessibility guidelines are updated these
should be fed into the updates of any codes of conduct/standards
agreements the EU arranges.
(d) On question 3 posed by the Sub-Committee—whilst
strongly supporting the agreement and adoption of codes of conduct,
RNIB would urge the EU institutions and Member States to be always
prepared to propose stronger intervention through legal or regulatory
means as far as practicable, where cases of inaccessible practices
by e-commerce providers are brought to the attention of the EU/member
state authorities and the providers prove unwilling to take simple
steps to make their services accessible to visually impaired or
other users.
28 February 2000
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